European Aviation Safety Agency NPA 2018-07(A)

2. In summary why and what

(3) ensuring the correct balance between implementing rules (IRs) and AMC & GM on the
subject issue.

2.3. How we want to achieve it overview of the proposals

Doc 9995 contains a complete competency f c ) with competency
descriptions and related behavioural indicators, encompassing what was previously known as both
technical and non-technical knowledge, skills and attitudes. This way, the training content is aligned
with the actual competencies necessary to operate safely, effectively and efficiently in a CAT
environment.
Following this rationale, EASA decided to contribute to the development of regulations that ensure
that pilot training and checking is adequate to provide a pilot with the necessary knowledge, skills and
attitude (KSA) to recognise and manage unexpected and unusual situations.
Traditional approaches to training development involve the decomposition of jobs into tasks. For each
task, there is a related objective, an assessment and associated elements in a training plan. A limitation
of this approach is that each task must be taught and assessed. In complex systems or when jobs
evolve rapidly, it may not be possible to teach and assess each task. Moreover, learners may
demonstrate the ability to perform tasks in isolation without being competent in their job.
Competency-based assessment and training on the other hand are based on the concept that
competencies are transferable. In the design of a competency-based assessment and training
programme, a limited number of competencies are defined and used across a variety of activities and
contexts.
As new technologies emerge and the complexity of the aviation system increases, the existence of a
competency framework is of key importance in order for pilots to be trained on complete and relevant
set of competencies. This competency framework should allow pilots to operate more safely,
effectively and efficiently in a CAT environment. Furthermore, should allow the training community to
adapt their training methods in order to manage unexpected events that are unforeseen through
reactive analyses. Mastering a finite number of competencies should allow a pilot to manage situations
in flight that are unforeseen by the industry and for which the pilot has not been specifically trained.
In 2014, ICAO established the Competencies Task Force. The task force proposals contained an
amended set of definitions for terms related to competencies, a description of how competency-
related concepts relate to one another and a generic methodology to design competency-based
assessment and training. Furthermore, the ICAO AN-WP/8962 established that many competency
frameworks were task-orientated. The task force also addressed the inconsistencies among these
different competency frameworks. In addition, it described the relationships between keys concepts in
competency-based assessment and training, and outlined the general principles and procedures to be
followed in the design and implementation of competency-based assessment and training.

TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 10 of 56
An agency of the European Union
 European Aviation Safety Agency NPA 2018-07(A)
2. In summary why and what

2.4. What are the expected benefits and drawbacks of the proposals
Studies23 show that the effective implementation of EBT should bring a significant contribution to
aviation safety by strengthening the competencies of flight crews and empowering them to handle
abnormal and unexpected situations safely. It is expected that the safety benefit of EBT would be
demonstrated over time by continually improving a system targeted at focused learning. The
implementation of the EBT programme should ensure a level of safety at least equivalent to that
provided by compliance with ORO.FC.230 of Annex III (Part-ORO) of the Air OPS Regulation and
Appendix 9 to (Part-FCL of the Aircrew Regulation. Safety benefits should be expected through a
qualitative approach, using competencies to develop resilience by exposure to varying and challenging
situations.
The level of education and training of personnel within AOC holders is expected to be improved due to
EBT. The EBT concept is designed to maximise learning and minimise formal checking. Where checking
is required, it should evolve towards measuring the process of managing situations rather than only
the outcome of this process. This will lead to a substantial change towards providing more learning
opportunities, by recognising the expectation that professionals should continuously strive to learn and
develop their capabilities, rather than only being focused on demonstrating performance according to
minimum regulatory standards. The pilots will be assessed and their licences will be revalidated based
on evidence from EBT evaluation modules and development of competencies throughout the EBT
programme, instead of an LPC. Therefore, the proposal is expected to have positive social impact on
the stakeholders (pilots, and organisations). Negative social impact is expected for the examiners
whose workload would be reduced due to the revalidation of the licences not based on a single
simulator session, but based on the evidence, gained through the EBT system. Reduced workload
might affect negatively the current role, position and the number of examiners. Although the amount
of training in EBT remains unchanged, the role of the trainer will be now performed under the
privileges of type rating instructor (TRI) licence, instead of type rating examiner (TRE) licence.
The cost-benefit analysis (CBA) for a medium/large operator with 1 000 pilots concludes that the
implementation of EBT in recurrent training and checking of flight crew is a cost-effective solution. It is
expected to cost 0.32 % more than the
expenditure that same operator makes for running traditional recurrent training and checking for its
pilots (very low negative economic impact in terms of costs). In addition, it has the potential to
generate significant economic benefits and to introduce an estimated saving of EUR 900 per pilot/year
which represent around EUR 900 000 saving per year for the operator which represents 0.02 % of the

shortly after 3 years of EBT implementation, considering that competent authorities grant full
economic alleviations to the operator. The CBA for a small operator with 100 pilots supports the
overall positive economic results. Similarly, to the medium/large operator, EBT has the potential to
reap significant economic benefits and to introduce an estimated saving of EUR 1 000 per pilot/year
which represents around EUR 100 000 saving per year for the operator. The profitability indicators
show that the return of investment is generated 4 years after EBT implementation, considering that
competent authorities grant economic alleviations to the operator. The net benefit represents around

23
There are numerous books and studies that support the benefits of competency based training Doc 9995, Doc 9868 PANS TRG ,
IATA Data report for EBT, IATA EBT implementation Guide and in the educational system:
based training in the Australian vocational education and training system (author Erica Smith).
TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 11 of 56
An agency of the European Union
 European Aviation Safety Agency NPA 2018-07(A)
2. In summary why and what

0.1 % of the annual turnover of a small operator. Despite that, a small operator may encounter
difficulties in EBT implementation that are exhaustively analysed in the RIA.
The requirement for inspectors to be competent in the approval of and the oversight over EBT
e short term
that will be offset with normalisation of the workload in the consecutive years in EBT oversight. In
addition, the workload and the relative costs for the competent authority are expected to decrease
with the time, as there might be a greater take-up of the EBT programmes by AOC holders. As EBT
implementation supports performance- and risk-based oversight, the overall impact on the competent
authority is considered very low negative in the first years and neutral in the consecutive years.
Finally, the regulatory impact assessment (RIA) illustrates that the proposed rules for voluntary
implementation of EBT by AOC holders contribute to maintaining a high level of aviation safety while
providing a cost-efficient and socially acceptable framework. The expected benefits and drawbacks of
the proposal are summarised below. For the full impact assessment of alternative options, please refer
to the IA.

TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 12 of 56
An agency of the European Union
 European Aviation Safety Agency NPA 2018-07(A)
3. Impact assessment (IA)

3. Impact assessment (IA)

3.1. What is the issue
Rapid technological changes and a diverse, dynamic and competitive operating environment create a
need for effective and efficient training aligned with the needs of the job. Traditional approaches to
training development involve decomposition of jobs into elements or tasks. For each task/element,
there is a related objective, an assessment, and the associated elements in a training plan. A limitation
of this approach is that each task/element must be taught and assessed. In complex systems or when
jobs evolve rapidly, it may not be possible to accommodate all these elements. Moreover, learners
may demonstrate the ability to perform any number of tasks without being competent in their job. In
that context, pilots need to be exposed to the unexpected in a learning environment, and be more
challenged and immersed in dealing with complex situations, rather than repetitively being tested in
the execution of specific predefined manoeuvres.
Furthermore, the checking of flight crew does not measure sufficiently the process of managing
situations, as it is mainly focused on the outcome of the process by demonstrating performance
according to minimum regulatory standards. Hence, it lags behind in providing more learning
opportunities and fails to meet the expectation that professionals should continuously strive to learn
and to develop their capabilities.
Competency-based training is a performance orientated approach in the assessment and training,
putting emphasis on performance standards and their measurement and developing training with
regard to the specified performance standard24. Competency-based training has been successfully used
across many industries. It is based on a job-related performance that encompasses technical task-
related skills and non-technical performance. The EBT approach to competency-based training is to

thus guaranteeing that what is trained and checked is relevant to the job.

3.2. Regulatory background and evolution

-based training within the

(GM) in order to promote a standardised and consistent means for the implementation of EBT within
the existing rule structure. This first step was completed with the publication of ED Decision
2015/027/R (published in December 2015) containing GM1 ORO.FC.230 and GM1 ORO.FC.A.245.
RMT.0696 followed an accelerated process within the existing regulatory system to bring forward the
safety benefits of EBT, by maintaining the existing IRs and AMC, in order to provide a robust safety net
until more experience in the EBT concept is gained.
RMT.0696 was planned as an interim step preceding RMT.0599 to gain EBT implementation experience
and thus identify certain difficulties and inconsistencies that will need to be addressed through
RMT.0599.

24
. ICAO DOC 9995 Definition
TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 13 of 56
An agency of the European Union
 European Aviation Safety Agency NPA 2018-07(A)
3. Impact assessment (IA)

Presently, EASA Member States (and other States that have elected to adhere to the European aviation
IRs) do not have a regulatory framework that lends itself to the full implementation of EBT. In fact,
within the current regulatory framework, it is only possible to achieve mixed EBT implementation25.
Data analyses26 reveal the difficulties encountered by pilots when faced with surprising or unexpected
situations. The commercial aviation system has a high level of safety reliability, but there remains a
resistant rate of serious and fatal accidents. The availability of substantial data allows a systemic
improvement, mostly through reactive redesign, improved operations, training and
maintenance/airworthiness activities. This improvement though will result in lead to a decreased rate
of serious and fatal accidents, which will become less predictable over time due to the difficulty in
predicting the root cause. Since complex linear models could not provide answers to these events,
alternative explanations are needed. They can be seen as due to an unexpected combination or
aggregation of conditions or events.
The continuous development of pilot core competencies is seen as an effective means to address what
will be unexpected and ultimately unforeseeable, the so-
facets of EBT is learning enabled through exposure to unexpected, dynamic and challenging situations.
Exposure during training to variable and dynamic threat conditions should help pilots develop and
improve their ability to handle unforeseen events. With variability of exposure, confidence should be
developed through the repetitive deployment of core competencies under many different conditions
and across the aircraft flight envelope. The EBT project is a global safety initiative whose objective was
to determine the relevance of existing pilot training and to identify the most critical areas of pilot
training according to aircraft generation. The outcome of this initiative was the publication of ICAO Doc
- , ICAO published Doc 9995 which contains the details
of a new approach to recurrent training and checking of flight crew. As part of RMT.0599, EASA
commits to the development of a dedicated regulation to enable the full deployment of EBT
programmes in accordance with the Doc 9995 philosophy.
The implementation of EBT within the European aviation regulatory framework is a paradigm shift,
assessing crew performance across a range of core competencies, rather than checking performance in
managing prescribed events. Training topics drawn from comparative risk analyses are used as a
vehicle for developing and assessing core competencies. Given the paradigm shift proposed by
competency-based programmes like EBT, one of the principal challenges for implementation is the
adaptation of the current instructor and examiner population to the concept. With this in mind,
competent authorities and operators implementing EBT should focus on the development of instructor
and examiner competencies.
The safety risk assessment and analysis of fatal aircraft accidents worldwide for the period 2001-2011
shows that in more than 50 % of these accidents the action of the flight crew was the primary causal
factor (CAA UK, 2013). This analysis shows that flight crew handling skills were a factor in 14 % of the
accidents, whereas flight crew non-technical skills were a factor in more than twice as many (32 %). It
is generally accepted that further improvements in flight safety require a comprehensive review of
pilot training (IATA, 2013), and the accident statistics show that the emphasis of this training should be
placed on the development of both the non-technical as well as the technical pilot skills.

25
Mixed EBT implementation means that only some portion of the recurrent assessment and training is dedicated to the application
of EBT.
26
IATA, Data Report for Evidence-based Training, First Edition, August 2014
TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 14 of 56
An agency of the European Union
 European Aviation Safety Agency NPA 2018-07(A)
3. Impact assessment (IA)

Traditional (legacy) recurrent training requirements for pilots operating with airlines are, largely, not
relevant to the operation of modern multi-crew transport category aeroplanes (IATA, 2011) and have
not kept up with the development of the operating environment. The current requirements are largely
based on the evidence of accidents involving early-generation jet aircraft (IATA, 2013) and do not
reflect the risks of the today operating environment.
Operators and industry bodies have recognised that the legacy training processes do not guarantee
that the trained pilots are competent, or they do not adequately addre
2013). Therefore, the implementation of EBT should be a first step towards the full implementation of
a competency-based training framework in all aspects of flight crew training and licensing.
The following SRs pertain to specific accidents/incidents. RMT.0599 will ensure that they are taken into
account in the scope of the recurrent EBT and checking, either as regards training events during the
for a specific core
competency:
FRAN-2013-017: The French Accident Investigation Board recommends that EASA, in coordination with
manufacturers, operators and major non-European aviation authorities ensure that go-around training
integrates instruction explaining the methodology for monitoring primary flight parameters, in
particular pitch, thrust then speed.
FRAN-2013-018: The French Accident Investigation Board recommends that EASA, in cooperation with
the national civil aviation authorities and major non-European aviation authorities, ensure that during
recurrent periodic training, training organizations and operators give greater importance to the
assessment and maintenance of the monitoring capabilities of public transport pilots.
FRAN-2013-022: The French Accident Investigation Board recommends that EASA review regulatory
requirements for initial and periodic training in order to ensure that go-arounds with all engines
operating are performed sufficiently frequently during training.
FRAN-2013-033: The French Accident Investigation Board recommends that EASA, in cooperation with
the national civil aviation authorities and major non-European aviation authorities, ensure that the
risks associated with dispersion and/or channelized attention during the go-around, to the detriment
of the primary flight parameters, be taught to crews.
FRAN-2013-035: The French Accident Investigation Board recommends that EASA, in coordination with
manufacturers, operators and major non-European aviation authorities, study whether to extend these
measures to other procedures requiring high workload in a short time frame.
FRAN-2014-005: The French Accident Investigation Board recommends that EASA, in coordination with
national authorities, make changes to the training requirements for pilots so as to include periodic
reminders on the effects of contaminants such as ice on stall and loss of control on take-off.
FRAN-2015-062: [unofficial translation]: EASA should define the terms on how an operator can set up a
risk-based training as described in Doc 9995. [French] [original text] - modalités
permettant à un exploitant de mettre en oeuvre la formation basée sur les risques telle que précisée
[Recommandation 2015-062]

TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 15 of 56
An agency of the European Union